A new EU clean air strategy up to 2030

At the very end of the EU’s “Year of Air” the European Commission finally presented its long-awaited new clean air policy package, including a proposal for member states to further cut their national air pollutant emissions up to 2030.

On 18 December environment commissioner Janez Potočnik announced the Commission’s plan for how to improve air quality in Europe over the next one and a half decades. The new strategy and the proposed measures are a follow-up to the 2005 Thematic Strategy on Air Pollution. They are based on the conclusions of a comprehensive two-year review of existing EU air policy, which also included extensive consultations that found broad support for EU-wide action to further reduce air pollutant emissions.

The new actions proposed are motivated by the fact that more than 400,000 people in the EU currently die prematurely from air pollution, and almost two-thirds of the EU ecosystem area is exposed to excess nitrogen emanating from air pollution. The damage to health has huge economic costs for society – for 2010 these were estimated to amount to between €330 and 940 billion, equalling 3–9 per cent of EU GDP.

There are four main components in Commission’s clean air policy package:

A Commission communication on a “Clean Air Programme for Europe”, which is a strategy document with measures aimed at meeting already existing targets in the short term (up to 2020), and new air quality objectives for the period up to 2030. It includes supporting measures to improve air quality in cities, support to research and innovation, and the promoting of international cooperation;

A main legislative proposal to revise the National Emission Ceilings (NEC) directive, setting new country-by-country emission reduction requirements up to 2030 for six main air pollutants;

A proposal for a new directive to reduce pollution from medium-sized combustion plants (MCP), such as local heating plants for smaller districts and small industrial installations; (see page 9) and,

A proposal to transpose into EU law the international emission reductions for 2020 that the EU has committed to under the 2012 Gothenburg Protocol of the Convention on Long-Range Transboundary Air Pollution (LRTAP).

To explain the analysis underpinning the strategy and proposals, the Commission in December also published a 360-page Impact Assessment report. In February-March, the impact assessment was supplemented by two additional reports with updated information – one describing the policy scenarios and another providing a cost-benefit analysis.

In the shortterm, up to 2020, the Commission’s main aim is to achieve compliance with existing air quality legislation. Many member states are failing to enforce existing EU air quality standards, and the Commission wants to address this by two types of measures:

Fix the light-duty diesel emissions problem: Real-world emissions of nitrogen oxides from Euro 5 diesel cars (as from 2009) have been shown to be much higher than expected, actually even higher than those of Euro 1 cars from 1992. A stricter type approval procedure and new “not-to-exceed” limit values should be in place as from 2017 to ensure that new cars will not exceed the Euro 6 emission limits under normal real-world driving conditions.

Support and improve air quality management: Local, regional and national air pollution control programmes will be able to get EU funding to implement actions to reduce air pollution. Guidelines for retrofit programmes and for promoting the use of advanced technology options will be developed, as will new tools to improve public information.

Despite the fact that the EU’s existing ambient air quality standards are still in some cases much less strict than recommended by the World Health Organization, there is no proposal to revise and strengthen these standards. The Commission only says that they will be revised “once the NEC directive has set background concentrations on the right downward track.” No year is given when this is expected to happen.

The emission reductions proposed in the NEC directive for 2020 are identical to those in the 2012 Gothenburg Protocol and are very modest, to say the least. These 2020 targets actually allow 10–25 per cent higher emissions of sulphur dioxide (SO2), nitrogen oxides (NOx) and non-methane volatile organic compounds (NMVOCs) than are expected to result solely from implementing existing legislation.

While the Commission’s Environment Directorate was originally pushing for binding emission reductions for 2025, internal negotiations with other Commission services resulted in a five-year postponement of the target year, to 2030, as well as a lowering of the overall ambition level.
So the final ambition level of the strategy – as set in the proposed revised NEC directive – is to cut EU-wide emissions of SO2 by 81 per cent; NOx by 69 per cent; NMVOCs by 50 per cent; ammonia (NH3) by 27 per cent; particulate matter (PM2.5) by 51 per cent; and, methane (CH4) by 33 per cent by 2030, compared to the emission levels in the base year 2005 (see Table 1).

Table 1: EU air pollutant emissions (in kilotons) in 2005 and projections for 2020 and 2030 assuming implementation of existing legislation (CLE) and compliance with emission reduction commitments (ERC) under the proposed new NEC directive.

2005

2020 CLE

2020 ERC

2020 NEC

2030 CLE

2030 ERC

2030 NEC

SO2

8172

2685

-59%

3351

2211

-81%

1530

NOx

11538

5591

-42%

6692

4051

-69%

3599

VOCs

9259

6152

-28%

6667

5460

-50%

4598

NH3

3928

3693

-6%

3692

3663

-27%

2871

PM2.5

1647

1370

-22%

1285

1200

-51%

804

CH4

20487

16349

n.a.

n.a.

15504

-33%

13676

Source: TSAP report No 11 (February 2014)

By 2030, and compared to business as usual, these emission reductions are estimated to avoid 58,000 air-pollution-related premature deaths, save 123,000 km2 of ecosystems from eutrophication by excess nitrogen pollution, of which 56,000 km2 are protected Natura 2000 areas, and save 19,000 km2 of forest ecosystems from acidification (see Table 2).

Table 2: Health and ecosystem impacts of air pollution in the EU in 2005 and under projected emission levels for 2030. CLE = assuming implementation of existing legislation; NEC = according to the proposed new NEC directive; MTFR = assuming implementation of current readily available technical emission control measures.

Million years of life lost due to PM2.5

Average loss of statistical life expectancy due to PM2.5 (months)

Annual cases of premature deaths due to O3

Ecosystem area with excess nitrogen deposition (1000 km2)

Natura 2000 areas with excess nitrogen deposition (1000 km2)

Forest area with excess acid deposition (1000 km2)

2005

358

8.5

24614

1148

427

161

2030 CLE

212

5.0

17239

871

329

42.0

2030 NEC

173

4.1

16160

748

273

22.7

2030 MTFR

152

3.6

14461

665

239

17.9

Source: TSAP report No 11 (February 2014)

As a result, health benefits alone will by 2030 save society €40-140 billion per year in external damage costs and provide about €3 billion per year in direct benefits due to higher productivity of the workforce, lower healthcare costs, higher crop yields and less damage to buildings.

Compared to the additional cost of pollution abatement resulting from the proposed actions, which is estimated to reach €3.3 billion per year in 2030, the health benefits alone outweigh this cost by up to 41 times. In addition, there will be substantial environmental benefits from reduced ecosystem damage – these are however difficult or in many cases impossible to monetise.

According to the Commission, the proposal will also add the equivalent of around 100,000 additional jobs due to increased productivity and competitiveness because of fewer workdays lost, and it is estimated to have a positive net impact on economic growth.

The NEC directive
Achieving the new strategy’s overall policy targets for health and environment by 2030 will require all member states to further cut their air pollutant emissions, and the principal legal instrument to ensure such reductions is the National Emissions Ceilings (NEC) directive. The main elements of the proposed new NEC directive are given below.

Reduction commitments
The proposed new NEC directive replaces the existing one from 2001 by keeping the current 2010 emission caps in place up to 2020, after which they will be replaced by percentage emission reduction commitments (ERCs) for 2020, in line with those already adopted in 2012 under the LRTAP Convention’s Gothenburg Protocol.

In addition, the new directive establishes more far-reaching legally binding ERCs to be achieved by 2030, as well as intermediate reduction targets for 2025. The latter are defined by a linear trajectory between the emission levels in 2020 and 2030. The country-by-country ERCs for 2020 and 2030 are contained in Annex II of the directive.

More pollutants
While the 2001 NEC directive covered four pollutants – SO2, NOx, NMVOCs and NH3 – the new one is also extended to cover fine particulate matter (PM2.5), with ERCs from 2020, and methane (CH4), with ERCs from 2030.

New flexibilities
A new feature is the introduction of certain flexibilities. Provided that the Commission does not object, member states will be allowed to:

Offset up to twenty per cent of emission reductions achieved by international shipping within their territorial seas or exclusive economic zones (up to 200 nautical miles from shore), if those ship emissions are lower than would result from compliance with EU standards;

Air pollution control programmes
Member states will be required to adopt, implement and regularly (every two years) update national air pollution control programmes, describing how they intend to meet their ERCs. In these programmes, member states shall include measures to cut emissions of NH3 and PM2.5 from agriculture and prioritise reduction measures for black carbon when achieving their national reductions of PM2.5. Moreover, member states shall subject their draft programmes to public consultation before finalisation.

Annex III of the directive lists the minimum content of the national control programmes, as well as a number of available cost-effective measures to control ammonia emissions from agriculture.

Reporting and monitoring
Every year member states shall update and report national emission inventories, not only for the pollutants covered by ERCs but also for other air pollutants covered by protocols of the LRTAP Convention. Projections of future emissions up to 2030 of the pollutants covered by ERCs shall be reported every two years. Reporting requirements are listed in the directive’s Annex I and IV.

Member states are also requested to systematically monitor air pollution impacts, using indicators – as specified in the directive’s Annex V – for eutrophication, acidification and ozone damage to terrestrial and freshwater ecosystems, and to apply methodologies established under the LRTAP Convention.

Five-yearly progress reports
At least every five years the Commission shall report to the European Parliament and the Council on the progress made towards implementing the directive, including an assessment of its contribution to achieving its objectives. However, in contrast to the 2001 NEC directive, there are no environmental objectives specified in the articles of the directive – instead they are referred to only in the preambular text.

While the directive itself does not set down any deadline for when the first Commission report is to be finalised, the Commission’s communication states that the first review of the “Clean Air for Europe Programme” will be done by 2020.

Access to information
Both member states and the Commission are obliged to “ensure the active and systematic dissemination to the public” by publishing information, such as the national air pollution control programmes and emission inventory reports, on publicly accessible internet sites.

Entry into force
The directive will enter into force on the day of its publication in the Official Journal of the European Union, and member states shall transpose the laws and regulations necessary to comply with the directive at latest 18 months after the entry into force.

A more ambitious climate policy would significantly lower the costs for air pollution control measures. The new climate policy targets of a 40-per-cent greenhouse reduction, as proposed by the Commission in January, would cut the annual costs of implementing the NEC directive in 2030 by more than one third, from €3.3 to €2.1 billion. In addition, the costs for implementing already existing air pollution legislation would come down by some €5 billion per year in 2030.

Because of the European elections this summer, the Parliament is expected to start its first reading of the air quality package only after the summer break. As a result, adoption of the new NEC and MCP directives is not expected until late 2014 or early 2015, at the earliest. If a second reading is required, adoption may be delayed until late 2015.

Christer Ågren

The policy package, including the communication, the legal proposals, the impact assessment and the Commission’s press release.The two additional reports with updated policy scenarios and cost-benefit analysis.
Reactions from environmental groups EEB and HEAL.

Air pollution impacts and objectives

More than 95 per cent of the EU’s urban citizens are exposed to harmful levels of PM2.5 and ozone, i.e. higher than the reference values recommended by the World Health Organization (WHO). Air pollution is the number one environmental cause of death in the EU, with over 400,000 premature deaths in 2010 – more than ten times the annual deaths from traffic accidents. For that same year, the external costs of health damage due to air pollution have been estimated to amount to €330–940 billion.

On top of these huge health impacts comes the damage to ecosystems, biodiversity, agricultural crops, cultural heritage and modern materials. Deposition of airborne nitrogen compounds in the EU exceeds the critical loads – the limits of nature’s tolerance – for eutrophication of vulnerable ecosystems over a total area of more than one million square kilometres. The critical loads for acidification are exceeded over vast areas of vulnerable forest and freshwater ecosystems, and elevated levels of ozone harm crops and natural vegetation, including forest trees.

For air pollution, the EU’s long-term objective is “to achieve levels of air quality that do not give rise to significant negative impacts or risks to human health and the environment.” For health this implies achievement of WHO health guidelines, and for the environment it means that the critical loads and levels should not be exceeded.

These objectives are not new, they have been in place since the EU’s 5th Environmental Action Programme (EAP), dating back to 1992, and were again confirmed in the 7th EAP, adopted on 20 November last year. Environmental groups want the long-term objectives to be achieved as soon as possible, at the latest by 2030.